Various substantive committees of the Section prepare written comments on procurement-related regulations in their areas of expertise. These comments are reviewed and approved by the Section's Officers and Council Members, then submitted to the appropriate government agency by the Section's Chair.
The Section's comments from August 1996 to the present are available online and may be accessed through the following topical index. Comments prepared prior to August 1996 are archived and can be obtained by contacting the Chair of the RCC.
Please note that the RCC has updated its Index of Comments by Topic with the twin goals of providing a more complete Index and making it easier to locate Section comments. As a result, some comments have been moved to new headings that are different from the heading indicated in the comment letter as submitted.
ABA Blanket Authority Handbook
Index of Comments by Topics
Many documents available on this site are in Adobe Acrobat format. A free copy of the Adobe Acrobat Reader is available from Adobe.
Accounting, Cost and Pricing
- CASB Staff Discussion Paper on Conformance of the Cost Accounting Standards to Generally Accepted Accounting Principles (CASB Case 2019–01), 84 Fed. Reg. 9143 (March 13, 2019)
- Comments on Department of Defense ("DoD") Guidebook for the Acquisition of Commercial Items, Part A Commercial Item Determination and Part B Commercial Pricing (Feb. 24, 2017)
- DFARS Case 2016-D017; Defense Federal Acquisition Regulation (Oct. 12, 2016)
- DFARS Case 2016-D002; Proposed Rule, Enhancing the Effectiveness of Independent Research and Development, 81 Fed. Reg. 7721 (Feb.16, 2016)
- Comments on Defense Federal Acquisition Regulation Supplement: Evaluating Price Reasonableness for Commercial Items; DFARS Case 2013-D034; 80 Fed. Reg. 45,918 (Aug. 3, 2015)